Preparing a Coliform Monitoring Plan
For noncommunity systems that don’t sample monthly
April 2016
DOH 331-240
(Revised)
Table of contents
COLIFORM MONITORING PLAN (CMP) 1
What to include in your Coliform Monitoring Plan 1
COLIFORM MONITORING PLAN TEMPLATE 6
EXAMPLE COLIFORM MONITORING PLAN 14
Example: Clean Water Resort 14
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COLIFORM MONITORING PLAN (CMP)
For noncommunity systems that don’t sample monthly
All Group A public water systems must collect samples for coliform bacteria analysis (chapter 246-290 WAC). This rule requires you to collect coliform samples from the distribution system and the source of supply. The specific basis for this monitoring is as follows:
· Distribution system monitoring requirements: The Revised Total Coliform Rule.
· Groundwater source monitoring requirements: The Groundwater Rule.
· Surface water source monitoring requirements: The Surface Water Treatment Rule.
Use this manual to develop your coliform monitoring plan. Keep the plan on file at your system and make it available to us upon request. Revise or expand the plan when it no longer ensures the samples you take represent your system’s water quality.
We developed this guidance manual for very small noncommunity groundwater water systems that serve fewer than 25 people at least one month of the year. This document includes instructions, one blank CMP form, and an example. We also provide information to help you respond to an E. coli-present sample from your source of supply or your distribution system.
This manual provides guidance for your distribution system monitoring based on the Revised Total Coliform Rule.
What to include in your Coliform Monitoring Plan
A. System Information
Include basic system information, including your Coliform Monitoring Population, which you can find on your Water Facility Inventory (WFI). Be sure to update your WFI if there is a change in the water system and submit it to us.
B. Laboratory Information
List the accredited laboratory that normally analyzes your coliform compliance samples. Include the contact information, hours of operation, and after-hours contact information. In addition, list the same information for another laboratory that could serve as a back up to your primary lab in case of an emergency.
C. Routine, Repeat, and Triggered Source Sample Locations
Choose good sample sites where you can collect water representative of the water system. An example of a good sample site is a cold-water faucet at a clean restroom sink. Do not select sites such as fire hydrants, frost-free faucets, or frost-free yard-hydrants. If possible, avoid swivel faucets, drinking fountains, faucets that leak or drip, or faucets close to the ground. See Coliform Sampling Procedures (DOH Pub. 331-225)* for proper sample collection instructions. Contact our regional office if you need help choosing sample sites.
ÿ Include the specific location of all routine sample sites. The “specific location” should include the address and the specific tap or faucet used.
ÿ Include the specific location of all repeat sample sites. The repeat sample sites should include:
1. The same tap as the original unsatisfactory routine sample.
2. An active service within five active connections upstream from the original routine sample location.
3. An active service within five active connections downstream from the original routine sample location.
You may propose repeat monitoring locations that better represent a pathway for contamination into the distribution system. With this approach in your CMP, you can specify either alternative fixed locations or a standard operating procedure (SOP) that defines criteria for selecting repeat sampling sites on a situational basis. You must design your SOP to focus the repeat samples at locations that best verify and determine the extent of potential contamination of the distribution system. You must submit the SOP to us for review and approval.
In addition to the three repeat samples, you must collect a source sample from a point prior to any treatment. Mark the sample type as “GWR” or “raw” to satisfy the triggered source sample requirement of the Groundwater Rule.
You must take repeat and triggered source samples within 24 hours after notification of an unsatisfactory routine sample. Repeat and triggered source samples will confirm the presence of contamination and help identify the source of contamination. Do not batch or shock chlorinate before collecting the repeat samples without prior authorization from us.
ÿ Include the specific location of a routine sample site for the following month. You must collect a sample in the following month even if your normal sample requirement for the following month is zero. If that following month is a month with zero population, the requirement for a routine sample will move to the first month that your population is greater than zero.
This section should also include advice on sample collection technique. For example:
· Remind sample collectors to evaluate the representative status of each sample site every time they collect a sample. This includes authorizing sample collectors to choose NOT to sample from a scheduled site if the evaluation reveals current or recent off-normal events at the sample site. Off-normal events include construction at the facility where the sample site is located, modification to the plumbing at the sample site, or an activity at the sample site that may have compromised the sanitary integrity of the sample faucet. Sample collectors should have the knowledge and authority to choose a different site when circumstances at a scheduled site make the site unsuitable to give a sample that represents the distribution water quality.
· Avoid collecting routine coliform samples during weeks that contain major holidays and vacations unless you know trained staff and lab capacity are available to respond to unsatisfactory sample results.
· Chlorinated systems should remind sample collectors to measure the free chlorine residual when they collect the sample. Collectors should note the measurement on the sample form they will submit to the lab with the sample.
D. Routine Sample Rotation Schedule
You should rotate routine sample sites each month that a routine sample is required. For example, if there are two routine sites, you should sample one site one month and the other site the next month that a sample is required.
E. Level 1 and Level 2 Assessment Contact Information
The Revised Total Coliform Rule includes several triggers that require you to assess your water system.
· Level 1 Assessment: Anyone familiar with your water system can do a Level 1 assessment
· Level 2 Assessment: Only a person we consider qualified can do a Level 2 assessment. This would include a professional engineer, water distribution manager 2 or above, or qualified staff from your local or state health department. Just because someone is qualified doesn’t mean that he or she will perform the work. You should contact two or more individuals in advance to see if they are willing to do the work and then include their names and contact information in your plan.
F. E. coli Response Plan
Your lab analyzes groundwater source samples and all unsatisfactory total coliform samples collected from the distribution system for the presence of E. coli bacteria. You should develop two E. coli-present response plans:
1. E. coli-present in a distribution system sample
2. E. coli-present in a groundwater sample
The checklists in this manual ask a series of questions to help you tailor a response plan to your water system. If the topic of a question requires more work for your water system, we suggest that you include the topic on a water system “to do” list. You should file the checklists with your Coliform Monitoring Plan (CMP). If you submit your CMP to us, you can choose whether to submit the checklists.
E. coli-present in a distribution system sample
The Revised Total Coliform Rule only requires immediate public notification (within 24 hours) when two related samples (a routine and one or more corresponding repeat samples) test positive for total coliform bacteria—and there is E. coli bacteria in one or more of the samples. In our experience, many customers appreciate it when their water system tells them about the presence of E. coli bacteria in a routine sample even when the rules do not require a notice. Early notification gives customers the opportunity to choose whether to consume the water before they boil it. There are pros and cons associated with early notification that your policy-makers should discuss while your CMP is under development; that is, before you discover E. coli bacteria in the drinking water.
The checklist helps you consider the following when developing your response plan:
Background Information
• Water system records detailing information such as new construction, water main breaks, and other off-normal events
• Status of Cross-Connection Control Program
• Status of treatment operation (if treatment present)
• Possibility of batch or temporary disinfection
• Availability of alternate water supply
• Map to help individuals know whether they are customers of your water system
• Details about water users: Type, location, accessibility to bottled water
• Logistics of message production: Language, necessary translations, printing
Policy Direction
Discussion with water system governing body
Governing body decision on timing of notice distribution
Potential Public Notice Delivery
Available methods for notice delivery
News release
Immediate Follow-up Action
E. coli-present in a groundwater source sample
If your source contains E. coli bacteria, your response to the corrective action requirements of the Groundwater Rule may take considerable time. Your E. coli-Present Response Plan should identify one or more steps you will take if the lab notifies you of an E. coli-present triggered source sample. Preparing a response plan before an E. coli-present sample result occurs should reduce the effect that an inadequately treated source will have on your water users.
When you develop your plan, you should consider:
Background Information
DOH sanitary surveys
Activities within wellhead protection area
Staff well-site inspections
Best practices used relative to work on well
Alternate Sources
Discontinue use of source
Intertie with adjacent system
Provide bottled water to all or part the distribution system
Construct a replacement source
Temporary Treatment
If continuous treatment exists, alter dose to provide 4-log virus treatment
Introduce chlorine at the source
Reduce pumping production and/or reconfigure operational storage
Alter consumption patterns
Alter the demand through conservation messages
Public Notice
Discuss content and distribution methods with policymakers and wholesale customers
Prepare templates
Immediate Follow-Up Action
The checklist for the E. coli-present groundwater sample asks you to evaluate the corrective action alternatives available to you under the Groundwater Rule to select the option that best fits your system. You may find out that you can chlorinate your source to provide adequate treatment to a large part of your service area, while the customers close to the source rely on boiling their water prior to consumption or using bottled water.
G. Attach a simple map or drawing of your water system
As appropriate for your system, show the source, pressure tank(s) and/or storage tank, treatment system, booster pumps, building(s), sample tap locations, and so on. Number each of the routine sites starting with X, for example X-1 or X2.
COLIFORM MONITORING PLAN TEMPLATE
For a Small Noncommunity Water System
A. System Information Plan Date: ______
Water System Name / County / System I.D. NumberName of Plan Preparer / Position / Daytime Phone #
Coliform Monitoring Population (January through December)
Source: DOH source number, Source name, Well depth, Pumping Capacity
Storage: List and describe
Pressure zones: Number and name
Population by pressure zone
Number of routine samples required monthly: / Number of sample sites needed to represent the distribution system:
B. Laboratory Information
Laboratory Name / Office Phone #Address / After Hours #
Hours of Operation
Contact Name
Emergency Laboratory Name / Office Phone #
Address / After Hours #
Hours of Operation
Contact Name
C. Routine, Repeat, and Triggered Source Sample Locations
Location/Address forRoutine Sample Sites / Location/Address for
Repeat and Triggered Source Sample Sites / Sample Location for Month Following an Unsatisfactory Sample when the following month normally doesn’t have a sample requirement
X1. / 1-1.
1-2.
1-3.
S0_ - well
X2. / 2-1.
2-2.
2-3.
S0_ - well
X3. / 3-1.
3-2.
3-3.
S0_ - well
If you need more than three routine sample sites to cover the distribution system, attach additional sheets as needed.
Important notes for sample collector:
______
D. Routine Sample Rotation Schedule
Month / Routine Site(s) / Month / Routine Site(s)January / July
February / August
March / September
April / October
May / November
June / December
E. Level 1 and Level 2 Assessment Contact Information
Name and Address / Office Phone ()-After Hours ()-
Cellphone ()- / Qualified for Level 2?
☐ Yes
☐ No
Name and Address / Office Phone ()-
After Hours ()-
Cellphone ()- / Qualified for Level 2?
☐ Yes
☐ No
F. E. coli-Present Sample Response
Distribution System E. coli Response ChecklistBackground Information / Yes / No / N/A / To Do List
We inform staff members about activities within the distribution system that could affect water quality. / ☐ / ☐ / ☐ / ☐
We document all water main breaks, construction and repair activities, and low pressure and outage incidents. / ☐ / ☐ / ☐ / ☐
We can easily access and review documentation on water main breaks, construction and repair activities, and low pressure and outage incidents. / ☐ / ☐ / ☐ / ☐
Our Cross-Connection Control Program is up-to-date. / ☐ / ☐ / ☐ / ☐
We test all cross-connection control devices annually as required, with easy access to the proper documentation. / ☐ / ☐ / ☐ / ☐
We have identified one or more individuals who are able to conduct a Level 2 assessment of our water system. / ☐ / ☐ / ☐ / ☐
We have procedures in place for disinfecting and flushing the water system if it becomes necessary. / ☐ / ☐ / ☐ / ☐
We can activate an emergency intertie with an adjacent water system in an emergency. / ☐ / ☐ / ☐ / ☐